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26 Early Spring 2013 UST COMPLIANCE TRENDS owners at least one month, in most cases, to resolve deficiencies before they reach a level where a fine may be imposed. For the latest information on how to stay in compliance with BUSTR regulations, please review the Underground Storage Tank Operational Compliance Field Guide located on the BUSTR website. following page shows the deficiencies most frequently cited by BUSTR Inspectors in 2012. In most cases, owners promptly provide information to BUSTR to quickly close deficiencies— sometimes within a couple of weeks. BUSTR uses a progressive enforcement approach giving There continues to be a large number of facilities with release detection deficiencies and assurance deficiencies. Deficiencies relating to the new BUSTR regulations concerning secondary containment and operator training have also increased. The table on the The Division of State Fire Marshal, Bureau of Underground Storage Tank Regulations (BUSTR) performs compliance inspections of all underground storage tanks (USTs) once every three years as required in the Federal Energy Act of 2005. In 2012, BUSTR performed inspections at 3,000 of 7,600 active facilities in Ohio. Of those, 1,050 sites had deficiencies of one type or another. Get An Inside Look: UST Compliance Trends

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Page 1: UST Get An Inside Lookfiles.ctctcdn.com/7fca34c4201/df60e6c2-749c-47ca... · Get An Inside Look: UST Compliance Trends. Early Spring 2013 27 UST COMPLIANCE TRENDS BUSTR is working

26 Early Spring 2013

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owners at least one month, in most cases, to resolve deficiencies before they reach a level where a fine may be imposed. For the latest information on how to stay in compliance with BUSTR regulations, please review the Underground Storage Tank Operational Compliance Field Guide located on the BUSTR website.

following page shows the deficiencies most frequently cited by BUSTR Inspectors in 2012.

In most cases, owners promptly provide information to BUSTR to quickly close deficiencies—sometimes within a couple of weeks. BUSTR uses a progressive enforcement approach giving

There continues to be a large number of facilities with release detection deficiencies and assurance deficiencies. Deficiencies relating to the new BUSTR regulations concerning secondary containment and operator training have also increased. The table on the

The Division of State

Fire Marshal, Bureau of

Underground Storage Tank

Regulations (BUSTR) performs

compliance inspections of all

underground storage tanks

(USTs) once every three years

as required in the Federal

Energy Act of 2005. In 2012,

BUSTR performed inspections

at 3,000 of 7,600 active

facilities in Ohio. Of those,

1,050 sites had deficiencies of

one type or another.

Get An Inside Look: UST Compliance Trends

Page 2: UST Get An Inside Lookfiles.ctctcdn.com/7fca34c4201/df60e6c2-749c-47ca... · Get An Inside Look: UST Compliance Trends. Early Spring 2013 27 UST COMPLIANCE TRENDS BUSTR is working

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BUSTR is working toward completion of the current three year operational compliance inspection cycle which officially ends in August 2013. The future plan focuses on release detection requirements encouraging UST owners and operators to maintain at least two years of records (as required by BUSTR rules). Also,

Page 3: UST Get An Inside Lookfiles.ctctcdn.com/7fca34c4201/df60e6c2-749c-47ca... · Get An Inside Look: UST Compliance Trends. Early Spring 2013 27 UST COMPLIANCE TRENDS BUSTR is working

Early Spring 201328

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most recent round of changes to the UST regulations. Additional federal rule changes may be on the horizon, and BUSTR looks forward to working with stakeholders to address these changes together.

The #1 BUSTR compliance

deficiency at an active

facility is failure to

perform an annual test

of the automatic line

leak detectors.

containments and sump sensors) when older single wall systems undergo certain types of work. We strongly encourage owners to review Performing Work on Existing UST Systems on the BUSTR website to identify the conditions that would trigger the above-mentioned secondary containment requirements.

With the combined efforts of BUSTR, the Ohio Petroleum Marketers & Convenience Store Association, and the Ohio Petroleum Contractors Association, tank owners are better prepared to adapt to the

during the future operational compliance inspection cycle, BUSTR will be asking owners and operators to provide copies of their certificates showing proof of completion of operator training. For those owners still seeking operator training, a list of approved trainers is available on the BUSTR website.

BUSTR has also received a number of inquiries regarding modifications to existing UST systems. Current regulations require the installation of secondary containment (double wall piping, dispenser

2012 Top BUSTR Compliance Deficiencies

Rank Frequency

1 572 Failure to perform annual test of the automatic line leak detectors

2 365 Failure to perform periodic test of pressure piping

3 302 Failure to comply with financial responsibility requirements (deductible coverage)

4 289 Failure to properly operate and maintain a monthly method of UST release detection

5 169 Failure to operate and maintain a corrosion protection system

6 133 Failure to submit annual registration application

7 124 Failure to provide proof of completion of operator training

8 122 Failure to demonstrate a valid certificate of coverage from PUSTRCB

9 89 Failure to perform tightness test of containment equipment every three years

10 79 Failure to provide proper overfill prevention on a suction system

By Steven Krichbaum, Bureau of Underground Storage Tank Regulations. For more information on BUSTR compliance inspection deficiencies, visit www.com.ohio.gov/fire/bustMain.aspx or call 614.752.7938 and ask to speak to a release prevention supervisor.